ap bct aar 10_2012_draft

Draft Alameda Point 1 of 10 TRVT-4408-0000-000X BCT Monthly Tracking Meeting 10/11/2012 www.bracpmo.navy.mil

DRAFT ALAMEDA POINT (AP)

BASE REALIGNMENT AND CLOSURE (BRAC) CLEANUP TEAM (BCT) MONTHLY TRACKING MEETING AFTER-ACTION REPORT

www.bracpmo.navy.mil October 11, 2012

MeetingAttendees:

Navy Derek Robinson Base Realignment and Closure (BRAC) Program

Management Office (PMO)-West, Environmental Coordinator (BEC)

Tony Guiang BRAC PMO-West RPM (via phone) Mary Parker BRAC PMO-West RPM

Regulatory Agencies

Isabella Alasti Department of Toxic Substances Control (DTSC) (by phone)

Tamarin Austin Regional Water Quality Control Board (W ater Board) (by phone)

Bob Carr U.S. Environmental Protection Agency (EPA) (via phone) Michelle Dalrymple DTSC David Elias Water Board James Fyfe DTSC Chris Lichens EPA Jim Polisini DTSC (by phone) Sophia Serda EPA Xuan-Mai Tran EPA John West Water Board

City of Alameda

Peter Russell Russell Resources/City of Alameda

Contractors Larry Dudus Tetra Tech EC Pete Everds Tetra Tech EC Dennis Kelly Tetra Tech EMI Ron Marnicio Tetra Tech EC (by phone) Betty Schmucker Trevet, Inc.


Meeting Objectives:

Finalize September 20, 2012, BCT Meeting Minutes Review Action Items Make Miscellaneous Announcements Discuss Operable Unit (OU) 2A Record of Decision (ROD) Wording Suggestions Discuss the Draft Alameda Point Finding of Suitability to Transfer (FOST) Discuss Responses to Comments (RTCs) for OU 5/Fleet and Industrial Supply Center

Oakland, Alameda Facility/Alameda Annex (FISCA) Installation Restoration (IR) Site 02

The meeting agenda is provided in Attachment A.

1.0 Introductions and Topics A. Introductions Introductions were made.

B. Finalize September 20, 2012 BCT Meeting Minutes Derek Robinson (Navy) asked for comments on the September 2012 BCT m eeting minutes. Xuan-Mai Tran (EPA) had one comment:

Page 7 of 7, item 5: Reword the action item to say “Navy (D. Robinson) to send IR-02 90% Remedial Design RTCs to BCT.”

The minutes were approved as final as revised.

C. Review of Action Items Mr. Robinson reviewed the lis t of new and pending action item s from the Septem ber BCT Meeting. See Section 5.0 for an updated list of action items.

D. Miscellaneous Announcements Mr. Robinson said there was a re quest to discuss suggested langua ge to be added to the OU-2A ROD, so that top ic was moved to the next item on the agenda. Jam es Fyfe (DTSC) requested that the Navy provide an update d list of current Navy RPMs a nd their respective duties for distribution to the BCT. Mr. Robinson agreed.

2.0 OU-2A RECORD OF DECISION Mr. Robinson said David Elias (Water Board) sent an e-mail to the BCT on Wednesday, October 10, with proposed language for the OU-2A ROD. Mr. Elias said the e-m ail outlined W ater Board concerns about the regulating tarry refine ry waste (TRW) and co-located total petroleum hydrocarbons (TPH) following proper ty transfer, and op tions for addressing those concerns. Option 1 presented in the e-mail was agreed to by the BCT; Mr. Robinson said he would run the wording past Navy Counsel to confirm. Option 1 is the addition of the following wording: “Any no CERCLA action for TRW or co-located petr oleum statements do not preclude the Regional Water Board from regulating the TRW or co-located petroleum in the future.”


Isabella Alasti (DTSC), Bob Carr (EPA), and Ta marin Austin (Water Board) concurred with the language. John West (Water Board) asked if the wording should go in the text rather than on the ROD signature page. Ms. Austin said she prefers the wording be added to the text. It was agreed to add the wording in Section 1.4, Statutory Determinations, pending concurrence from Navy Counsel.

Peter Russell (City of Alameda [City]) said the City would like regulatory finality on handling the TRW issue prior to transfer, but Com prehensive Environmental Response, Compensation, and Liability Act (CERCLA) is not the proper venue for that. He wondered how restrictions, if needed, would be im plemented. Mr. Robinson sa id that Option 1, cited above, would be i n addition to existing FOST language that states that redevelopm ent in the TRW areas will be subject to a Soil Managem ent Plan agreed upo n between the Water Board and the City. M r. Elias said the FOST will requ ire TRW and co-loc ated petroleum areas to be res tricted from residential development and the W ater Board would be the covenantee. The W ater Board has the authority to regulate TRW and co-located pe troleum, and restric tions on residential reuse would be needed. Mr. Carr said this would proba bly not be a deed restri ction, but cited in the FOST as a land use covenant to be executed in conjunction with the property transfer. Mr. Robinson said Navy Counsel prefers not to have a deed restriction. Dr. Russell thanked everyone for supporting the City’s concerns on this.

Ms. Tran said she might have some minor wording changes in the OU-2A ROD comments. Mr. Robinson noted that Tony Guiang (Navy) is taking over as OU-2A RPM since Curtis Moss left.

3.0 Draft FOST Mr. Robinson summarized the status of the Draft FOST sent out on September 21 to the BCT for review. Comments are due to the Navy on October 23. Mr. Robinson said the Navy needs to tie up the status of Sites 6, 16 (Operating Properly and Successfully, or O PS), and 7 (no further action). T he Navy is developing land use c ontrol (LUC) restrictions for OU-2A. The restrictions will be referenced in FOST.

Mr. West asked if DTSC will be the lead later on for CERCLA restrictions. Mr. Robinson said yes. Dr. Russell is putting togeth er a table and figures showing restricted areas and these should be ready early nex t week. The figu res will show sites that have received OPS designation but have not yet reached rem ediation goals (RGs), as well as TRW areas. Dr. Russell said the table and figures should go into both the FOST and the d eed as part of restricted areas. Mr. Robinson said the City and Water Board are discussing how petroleum restrictions will be handled. Navy Counsel needs to see the language that is agr eed upon. Mr. West noted that other BRAC bases must have wording already in place for addressing petroleum restrictions and the same or similar language could be used for Ala meda. Mr. Elias suggested a working m eeting with Navy Counsel (Marvin Norman) to develop language and post-transfer process. He not ed that the Water Board and the City are working hard on this, and he has gotten conflicting inform ation from title companies, the deed recorder, etc.

Mr. Robinson said the one of th e Navy’s post-transfer concerns is petroleum and future Navy liability. The Navy would like third-party over sight to prevent a future developer from improperly excavating and dispos ing of soil with TPH, and f iling a claim with the Navy f or addressing the disposal costs. Future developers must be aware of the conditions. Mr. Elias said


a working m eeting should be held now to ca rve out im pacted areas and hamm er out the restriction process.

Mr. Carr raised the topic of ac tions to be conducted after the OU-2A ROD is signed. He noted that the ROD provides for Re medial Design (RD) and wondered how to m ake sure all appropriate mechanisms are avai lable to support the FOST and fo r inclusion in the RD. Mr. Robinson said OU-2A has TRW in the FOST foot print and groundwater rest rictions at Sites 9 and 19. A LUC RD is being de veloped now. For CERCLA rest rictions, DTSC will be th e enforcer of land use restrictions following tran sfer. Mr. Elias said he would like to see the footprint of the restric tions on petroleum sites, not jus t TRW. Dr. Russell said there is minimal overlap between TRW and other petroleum sites. Mr. Elias said it’s important to know where the LUCs are so they may be referenced for future site closures.

Mr. Carr as ked if the F OST will in clude restrictions on OP S sites tha t have inter im land use restrictions. Mr. Robinson said yes, groundwater restrictions will be placed on sites 6, 14, and 16 for future development p rior to reaching RGs. Site 28 is an ex ception. Mr. Carr said he thinks the FOST restrictions are perhaps a little more restrictive than needed, but it may be better to leave them as written until the RGs are achieve d. Dr. Russell sa id the restrictions are often only for a plum e and a 100-foot buffer, not an en tire site. Mr. Robins on said the restrictive language is designed to allow the Navy to com plete its work on sites still in active remediation. Dr. Russell mentioned Site 27 as a special cas e, with a restriction on the en tire site before the Groundwater Beneficial Use Exception was granted.

Dr. Russell said that F igure 2 in th e Draft FOST shows that OU-2C is not within the FOST footprint because the R OD is not com pleted, but he wondered if Storm Drain Line F is part of OU-2C. M s. Parker said the line was rem oved as part of a Ti me-Critical Removal Action (TCRA). Mr. Robinson said Line F is not part of OU-2C. Mr. Carr said the question should be, can the Navy can give a CERCLA covenant stating that all rem edial action has been com pleted with respect to the sto rm drain line s that we re removed. Dr. Russell asked Mr. Carr if BCT concurrence with the Sites 5 & 10 TCRA Comp letion Report would suffice; Mr. Carr said he thought so but would have to check.

Mr. Robinson noted that the Navy wishes to transfer the FOST property to the City by December 2012. BCT comments on the Draft FOST are due October 23 and Mr. Robinson asked if anyone needs an extension to meet that deadline. Ms. Tran said the EPA needs information on Sites 6, 7, and 16. Mr. W est said the Water Board should be able to make the comment deadline but will talk with other Water Board staff. Mr. Fyfe said DTSC is reviewing th e FOST; however, there may be other steps to go through to com plete DTSC responsibilities for the FOST, and he will check on those. Ms. Alasti is reviewing the FOST.

Ms. Tran asked about definition of the Site 32 p arcel boundary. Mr. Robinson said by the tim e the Final FOST is prepared th e parcel boundary will be define d, although the m ap may need to be updated to exclude Site 32. The site m ay be divided for transfer, as part will go to the Veterans Administration (VA). Mr. Robinson summarized the status of Site 32 work and noted that additional areas will be inves tigated and possibly rem oved (where survey results exceed 3 times sigma); however, the investigation m ust be com pleted before the site boundary can be drawn. Dr. Russell asked if th e site boundary m ight move further east. Mr. R obinson said probably not, but it is possible the site boundary may move further south, which might affect the


VA transfer. He described the pos sible worst-case scenario using a diagonal street to divide Site 32, allowing the eastern part to be transfe rred and keeping the western part for further investigation. Mr. West asked if California Department of Public Health (CDPH) will review the FOST in a timely manner. Mr. Robinson said C DPH does not need to review. Mr. F yfe said if CDPH cannot complete its radiological scans for the FOST, the FOST can go through but CDPH will prepare a written s tatement, with language similar to lead-based p aint language, indicating that the Navy retains responsibility but the City can still accept the property. DTSC will put this in its FOST comments.

Mr. Elias said the Water Board will like ly prepare a cleanup and abatement order (C AO) to the City and the Navy for open sites. This is gene rally done when property is transferred to m ake sure someone retains responsibility post-transfer, but will depend on final disposition of the FOST sites. Mr. W est noted that a CAO is tri ggered by need, so an order can be prepared but held back until or unless something goes wrong, and then the orde r would be issued. The Board looks at need, tim eline for cleanups, and budget issu es, and at what is r easonable. Dr. Russell asked if there are any exceptions to doing this “generally.” Mr. Elias said he would guess that an exception might be if the Navy is so thoroughly engaged with ongoing cleanup that there is little need to bring in another entity to make sur e the cleanup is completed. Mr. Robinson said the Navy is not transf erring petroleum liability with the property, so there is less n eed for a CAO. Mr. Elias agreed that since liability is not being transferred, it may affect the need for a CAO. He said, Terry Seward, Acting Chief of the Gr oundwater Protection a nd Waste Containment Division, is requesting the CAO.

Mr. Carr asked when EPA would get outstanding responses to comm ent (RTCs) for Sites 6, 7, and 16. Mr. Robinson said he will talk with Da ve Darrow (Navy) and get a date to the BCT. Mr. Carr said the FOST is subject to a 30-da y public comment period and the schedule m ay be an issue. He noted that at th e beginning of the FOST there is a yellow flag stating that some documents are still under review by regulators, and he is concerne d about meeting the schedule. Mr. Robinson thanked everyone for working on the FOST as it is a high priority.

4.0 RTCs for OU-5/FISCA IR02 Mary Parker (Navy) introduced the discussion of RTCs on the Draft T echnical Memorandum (TM) for the OU-5/FIS CA IR-02 groundwater data evaluation. Sh e said that this discussion would primarily focus on the risk -evaluation component of the RT Cs that was e-m ailed to the BCT last week. She explained th at vapor intrusion (VI) is consid ered the key risk pathway for OU-5/FISCA IR-02 groundwater discussion based on regulatory agency comments on the TM. The contaminants of concern (COCs) for the si te are benzene and naphthalene. A biosparging system is operating at OU-5/FISCA IR-02. Ms. Parker introduced Ron Marnicio (Contractor) to present the findings in A ttachment A of the RTCs and to answer risk que stions. Attachment A was emailed to the BCT on October 5.

Dr. Marnicio summarized the background and base line risk assessments previously conducted. He reviewed the hum an health risk assessm ents that were run to calculate residential risk. The Navy evaluated the previous soil and groundwater da ta using current criter ia and the results are presented in Attachment A. He noted that chang es in modeling and contaminants evaluated for indoor air VI have changed since 2004 and were c onsidered in developing Attachment A. Older


models used site-specific m igration models, and now attenuation factors are considered in the modeling. Naphthalene is evaluated as part of VI risk.

Jim Polisini (DTSC) said he has an issue with site characterization and the use of old data, rather than with the risk ass essment process in Att achment A. He recomme nded that additional sampling be conducted. Ms. Parker said that she thought the existing data are best to use in the risk evaluation because the exis ting data ar e well dis tributed and would dem onstrate the maximum concentrations (pre-b iosparging) for risk evalua tion. She said that once the biosparging system is turned off, it could take 6 to 9 m onths for groundwater to reach equilibrium, which should occur prior to collecting sam ples to be representative of future long-term site conditions.

Mr. Robinson asked if Dr. Polisini thought the approach seemed reasonable. He noted that using older data (som e up to 10 years old) m akes the Navy’s assum ptions more conservative. Dr. Polisini asked if the data in Table 2B reflected the Marsh Crust as the contam inant source; Mr. Robinson said yes. Dr. Polisini said the data in Tables A-2B and 2N do not appear to support the conceptual site model (CSM) of M arsh Crust as the contaminant source, since higher benzene and naphthalene concentrations are not found in the deeper sa mples (at 5 feet below ground surface [bgs]) at a number of locations. He reiterated his concern that VI risk is being calculated on old data, rather than on current conditions. Ms. Parker noted that in the contex t of all data, the deeper data show higher COC concentrations . She clarified th at the Draft TM includes a table showing the vertical data distribution, includ ing at depths closer to the March Crust, which is at approximately 18 feet bgs, not 5 feet bgs, and the data do support the CSM of Marsh Crust as the source of groundwater contamination.

Mr. Robinson asked D r. Polisini if he would lik e to see new vapor data collected after th e biosparging system is turned off. Dr. Polisini suggested shut ting down the system permanently until new data ar e available. M s. Parker was concerned that it could take m onths to rea ch equilibrium in order to take sam ples, and analysis of all data colle cted to date show risk in the risk management range or lower. Ms. Parker noted that recent monitoring results show increases in oxygen along the groundwater plum e perimeter, and that would be lost if the system is turned off.

Sophia Serda (EPA) said she agreed with Dr. Polisini about the ag e of the data. She perform ed independent calculations using the Navy’s data in the EPA’s generic risk m odel and found that VI risk for naphthalene and benzene exceeds the cancer target risk range. She said VI is a complex topic and is m uch better understood now than 10 years ago. She asked if any sub-slab soil gas data were available. Ms. Parker said some of the data came from building crawl spaces. Chris Lichens (EPA) said there m ay or may not be a complete understanding of the site CSM, and it must be understood to correctly understand VI risk. Ms. Parker said that site-specific data were used in site-specific m odeling, and the site has been thoroughl y investigated. Lots of soil gas and groundwater data have been collected and continuous coring has been perform ed. The Navy would like to m ove forward with the R OD Amendment based on th e evaluation of the existing site data. Mr. Lichens said that risk should not be overlooked in the process of moving forward, and Ms. Parker agreed.

Mr. Robinson said that the OU-5/F ISCA IR-02 ROD documented that risk was within the risk management range unless the groundwater is used for drinking water, which is unlikely, but the


Navy did install a biosparging tr eatment system. The TM w as prepared to show that the hum an health risk evaluation performed during the Feasibility Study (FS) was satisfactory, and that the risk was acceptab le then and rem ains so toda y. That is why the TM evaluation is m ore qualitative than quantitative. In an April 2012 meeting the regulatory agency management agreed it was acceptable to u se the existing data, and it was ag reed that a dditional data were not necessary. Therefore, the Navy would like to move forward with a ROD Amendment for OU-5/FISCA IR-02 groundwater. Dr . Russell asked for clarificati on of the content of the ROD Amendment, and Ms. Parker clarified that the ROD Amendment would state no further action is required. Mr. Robinson asked the BCT if they ag reed sufficient information exists to move forward, or what other evaluations might be needed.

Michelle Dalrymple (DTSC) asked if domestic use of groundwater was evaluated in the original FS risk assessment; Ms. Parker said yes, and cited the ROD regarding drinking water and non-potable groundwater use. Ms. Dalrymple asked if there was a for mal beneficial use exception, and Ms. Parker said yes for the FISCA IR-02 ( eastern) portion but not for the OU-5 (western) portion. Dr. Russell asked if RGs need to b e ratcheted up to reflect groundwater concentrations protective of VI; Ms. Parker said no, the risk is in the risk management range. Mr. Fyfe asked if the RGs can be ignored on the portion without a beneficial us e exception. Mr. Robinson said institutional controls are in place for FISCA IR- 02. He told the BCT that the Navy can evaluate the existing data for a ROD Amendment. If the BCT doesn’t believe this, he asked what samples they think are needed, how m any are needed, and where they shoul d be located. He asked if a qualitative data review would be useful. Mr. Lichens said EPA will think about the sampling but he has no answer right now. He asked if the Navy has any options other than a ROD Amendment. Mr. Robinson said that Navy m anagement has said the ROD Am endment is preferred; however, if there is agreement that additional data are required and those data results show something very different from previous results, then a ROD Am endment would not be possible.

Dr. Marnicio continued with the A ttachment A presentation. Crawl-space data for indoor air inhalation risk at North Housing and Kollm an Circle residences were evaluated (Table A-1) using DTSC’s attenuation factor. The results show benzene is within the risk management range and the hazard quotient (HQ) is below 1.0. Samp le locations are shown on Figure A-1. Indoor air inhalation risk data for be nzene in so il gas were eva luated (Table A-2B) and results show benzene is within the risk m anagement range and the HQ is well below 1.0. Sa mple locations are shown on Figure A-2. Mr. Robinson asked th e BCT if outdoor air samp le values are higher than the crawl space results, why is risk an issue. Dr. Se rda said the Kollman Circle samples were not evaluated for naphthalene in 2002, just benzene. The concern then was whether residents needed to be moved out of their homes, not whether VI was a concern for future reuse.

Dr. Marnicio summ arized the benzene and na phthalene groundwater concentrations fro m samples taken in 2001 and some in 2007 (Table A-3). The Navy re-evaluated groundwater from Hydropunch® samples taken as close as possible to the original groundwater sampling locations, and performed site-specific modeling at four “worst-case” locations where shallow groundwater concentrations were highest and where soil t ype and thickness would allow VI. Ms. Dalrym ple asked the Navy to expand Table A-3 to explain w hy data were either in cluded or excluded; Ms. Parker agreed. Ms. Dalrymple asked if any monitoring wells were sampled and Ms. Parker said yes, but they had longer screened intervals. Mr . Dudus said the wells we re screened across the


whole groundwater interval, and Ms. Dalrymple noted that this would provide a conduit for contaminant access at all groundwater levels.

Dr. Marnicio noted that results presented in Table A-4 for be nzene and naphthalene indoor air inhalation risk at the four “worst-case” locations were all within the risk management range and with HQs less than 1.0. Dr. Serda requested that the Navy expand Table A-4 with infor mation on projected indoor air concentrat ions and provide this infor mation to the BCT. The Navy agreed to prepare the revisions.

Dr. Marnicio explained that Hydropunch ® groundwater samples are typically turbid and that higher naphthalene m ay be the result of sample characteristics. Dr. Serda noted that th e technology for detecting naphthalene has only gotten better over the last few years. Mr. Lichens said that EPA needs time to discuss this and does not have an answer yet regarding additional sampling. Ms. Parker asked if the Navy can have BCT input by the end of October regarding moving forward with the ROD Am endment. Mr. Robinson asked if the TM and Attachm ent A provide sufficient qualitative and quantitative analysis to move forward to a ROD Am endment, assuming that any new data, if collected, do not demonstrate something different. He would like a response from EPA and DTSC on this before making any commitment to new sampling. Ms. Dalrymple asked if the biosparging system is still running and whether the Navy would shut down the system before sam pling. Ms. Parker said the system is still running, and the Navy would want EPA and DTSC agreement bef ore shutting down the b iosparging system to collect additional samples, if that is what is decided on.

Mr. West summarized the questions as follows: 1) Is the risk analysis conducted to date good enough to move forward with a ROD Amendment, assuming more sampling may be done? 2) If samples are to be taken , what are the param eters? 3) If the new data depart fro m the current CSM, what would be the next step?

Dr. Polisini asked if the Water Bo ard could issue a formal declaration of groundwater beneficial use exception. What groundwater samples would be used to support this, before biosparge shut-down or after? He asked if it would be possible to get data both pre- and post-system shut-down. He noted that the biosparge system would need to be reactivated if the data show more treatment is necessary. Mr. Robinson said the Navy received a groundwater beneficial use exception letter for the FISCA IR-02 ( eastern) portion and asked about the basis for that. Ms. Parker said she believed it was based on total dissolved solids (TDS), sim ilar to the Septem ber 2012 use exception letter for the s outheast corner of AP. Mr . West said that the same steps could be done for OU-5 as was done for the September letter, looki ng at data for TDS, salinity, etc. Mr. Fyfe said he would like to discuss this w ith Ms. Alasti. Mr. Lichens said a response by EPA to the three questions, above, m ay be possible by the end of October; Mr. West and Mr. Fyfe agreed with this time frame.

5.0 Other Discussion and Action Items Mr. Robinson reminded BCT members of the public Proposed Plan m eeting for OU-2C to be held this evening in this build ing. It w ill be a poster board sess ion with opportunity for comments. A pre-meeting will be held with RAB members to discuss the OU-2C Proposed Plan.


Action Items Action Item Update

1. Ms. Tran to send her comments on the write-up of the OPS discussion between the attorneys and distribute to BCT.

Pending

2. Navy (T. Guiang) to look at pH soil data for Site 28 and update the regulatory agencies.

Complete

3. Navy (D. Robinson) to send IR-02 90% Remedial Design RTCs to BCT.

Pending

4. Navy (T. Guiang) to prepare a technical memorandum to discuss TRW; D. Robinson to provide timeline.

Pending

5. Navy to evaluate whether TPH co-located with TRW was evaluated in the appropriate CERCLA document.

Complete

6. Navy to route the OU-2A iROD signature page to Ms. Toth at DTSC first in order to get her signature before vacation.

Complete

7. Navy (D. Robinson) to email the updated SMP schedule.

Complete

8. Navy (D. Robinson) to email the draft FOST to the BCT; BCT members will prioritize review of the FOST and let the Navy know if they need to request an extension on anything else so they can focus on the FOST.

Complete

9. BCT members to hold a place on their calendars for the day of October 11, 2012, prior to the OU-2C Proposed Plan meeting, to have an in-person discussion on the FOST.

Complete


10. Navy (D. Robinson) to send updated list of Navy RPMs and respective duties. 11. DTSC (J. Fyfe) to send information on copper concentrations from spring sampling soil data results to J. Polisini. 12. Navy (D. Robinson) to forward document on Sites 6, 7, and 16 to the BCT by October 16. 13. Navy (M. Parker to expand Attachment A Table A-3 in OU-5/IR-02 VI Tech Memo with more information on rationale for using data. 14. Navy (M. Parker) to expand Table A-4 in Tech Memo on VI (Attachment A) with information on projected indoor air concentrations and send to BCT at the end of October. 15. BCT members to provide feedback to Navy by end of October on whether the Navy can move forward with the ROD Amendment based on the risk evaluations conducted to date, and if additional sampling is needed for OU-5/IR-02. If so, suggested locations and parameters should also be provided.

Pending

Pending

Pending

Pending

Pending

Pending

The BCT meeting was adjourned.

ATTACHMENT A

ALAMEDA POINT BCT MONTHLY MEETING AGENDA

October 11, 2012

(1 Page)

ap bct aar 10_2012_draft

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